Central Green Co. v. United States
Encyclopedia
Central Green Co. v. United States, 531 U.S. 425 (2001), was a United States Supreme Court
case decided in 2001. The case concerned the meaning of the words "flood or flood waters" within the Flood Control Act of 1928
. The Court concluded that the law did not always apply to federal flood control facilities.
flowed through their property. In 1996, they brought a suit against the United States alleging negligence in the operation and design of the canal. They alleged that it causes subsurface flooding which destroyed some of their crop. In court, the United States argued that the Flood Control Act of 1928 grants them immunity, as it states "[n]o liability of any kind shall attach to or rest upon the United States for any damage from or by floods or flood waters at any place". The District Court dismissed the complaint, agreeing with the United States that this incident would fall in the confines of "flood or flood waters". Central Green Co. appealed and the Ninth Circuit Court of Appeals affirmed. It agreed with Central Green that the Madera Canal "serves no flood control purpose", but nevertheless held that immunity attached "solely because it is a branch of the Central Valley Project". Central Green appealed again, this time to the United States Supreme Court, which granted review
.
wrote the decision of the Court, which was unanimous. Stevens began by stating a prior case bound the Court
to a different interpretation of the phrase "floods or flood waters" than the Ninth Circuit. In James v. United States (1986), the Court found the phrase "floods or flood waters" encompassed waters released for flood control purposes when reservoired waters are at flood stage. He went on to write that it was a difficult 'fact-led' question about whether this singular incident would fall within the James decision. For that reason, the Court would allow the suit to proceed in the District Court, only concluding that it was in error for the Government to receive absolute immunity in this case. Therefore, the Ninth Circuit was reversed.
Supreme Court of the United States
The Supreme Court of the United States is the highest court in the United States. It has ultimate appellate jurisdiction over all state and federal courts, and original jurisdiction over a small range of cases...
case decided in 2001. The case concerned the meaning of the words "flood or flood waters" within the Flood Control Act of 1928
Flood Control Act of 1928
The Flood Control Act of 1928 authorized the U.S. Army Corps of Engineers to design and construct projects for the control of floods on the Mississippi River and its tributaries as well as the Sacramento River in California. It was sponsored by Sen. Wesley L. Jones of Washington and Rep. Frank R...
. The Court concluded that the law did not always apply to federal flood control facilities.
Background
Central Green Co. owned 1,000 acres of pistachio orchards in California's San Joaquin Valley. The Madera CanalMadera Canal
The Madera Canal is a aqueduct in the U.S. state of California. It is part of the Central Valley Project managed by the United States Bureau of Reclamation to convey water north to augment irrigation capacity in Madera County, California. It was also the subject of the United States Supreme...
flowed through their property. In 1996, they brought a suit against the United States alleging negligence in the operation and design of the canal. They alleged that it causes subsurface flooding which destroyed some of their crop. In court, the United States argued that the Flood Control Act of 1928 grants them immunity, as it states "[n]o liability of any kind shall attach to or rest upon the United States for any damage from or by floods or flood waters at any place". The District Court dismissed the complaint, agreeing with the United States that this incident would fall in the confines of "flood or flood waters". Central Green Co. appealed and the Ninth Circuit Court of Appeals affirmed. It agreed with Central Green that the Madera Canal "serves no flood control purpose", but nevertheless held that immunity attached "solely because it is a branch of the Central Valley Project". Central Green appealed again, this time to the United States Supreme Court, which granted review
Certiorari
Certiorari is a type of writ seeking judicial review, recognized in U.S., Roman, English, Philippine, and other law. Certiorari is the present passive infinitive of the Latin certiorare...
.
Opinion of the Court
Justice StevensJohn Paul Stevens
John Paul Stevens served as an Associate Justice of the Supreme Court of the United States from December 19, 1975 until his retirement on June 29, 2010. At the time of his retirement, he was the oldest member of the Court and the third-longest serving justice in the Court's history...
wrote the decision of the Court, which was unanimous. Stevens began by stating a prior case bound the Court
Stare decisis
Stare decisis is a legal principle by which judges are obliged to respect the precedents established by prior decisions...
to a different interpretation of the phrase "floods or flood waters" than the Ninth Circuit. In James v. United States (1986), the Court found the phrase "floods or flood waters" encompassed waters released for flood control purposes when reservoired waters are at flood stage. He went on to write that it was a difficult 'fact-led' question about whether this singular incident would fall within the James decision. For that reason, the Court would allow the suit to proceed in the District Court, only concluding that it was in error for the Government to receive absolute immunity in this case. Therefore, the Ninth Circuit was reversed.